Quick Answer: Financial institutions examined in 2025 revealed critical gaps in continuous compliance, AI governance, and vendor management. For 2026, banks and credit unions should implement ongoing documentation systems, establish AI policies with risk thresholds, strengthen third-party risk assessments, and shift security reporting from technical metrics to business impact language.
Cybersecurity is no longer just a technical concern—it's central to business strategy, regulatory compliance, and customer trust. Examination trends from 2025 reveal what regulators will scrutinize in 2026. Understanding these patterns helps financial institutions prioritize investments and avoid common compliance gaps.
Check out the Cyber Risk Management Model that examiners reference below
The Finding: Most institutions scramble annually to gather evidence and prepare for exams, creating inefficiency and stress.
What One Institution Did Right: One bank in the Rivial community shifted to a continuous compliance model with ongoing documentation and automated evidence collection. Result: approximately 12 cumulative hours saved across reviews, minimal examiner feedback, and a stress-free post-exam period.
Your Action Items:
Why It Matters: Continuous compliance demonstrates institutional maturity to examiners and reduces the chaos of last-minute evidence gathering.
The Finding: Examiners now prefer hands-on, demonstrable security responses—not theoretical discussions.
What Examiners Want to See:
Your Action Items:
Why It Matters: Functional testing proves your institution can actually respond to incidents, not just talk about it.
The Finding: Examiners are intensifying scrutiny on vulnerability management and vendor risk, particularly fintech partnerships and cloud services.
Common Gaps:
Your Action Items:
Why It Matters: Vendor compromise is a primary attack vector. Examiners expect documented, tiered vendor management based on risk level and function.
Why It Matters: AI adoption is accelerating. Examiners expect clear policies, risk assessments, and incident response plans—not blanket bans or unmanaged adoption.
What AI Governance Should Include:
| Element | Implementation |
|---|---|
| AI Policy | Clear approval/prohibition criteria for AI tools |
| Risk Assessment | Cyber, operational, ethical, and regulatory dimensions |
| Vendor Management | AI vendors assessed against your framework |
| Incident Response | Playbooks for model drift, bias, data leakage |
| Monitoring | Tools like Microsoft Purview to track employee AI use |
| Training | Staff education on AI risks and appropriate use |
Real Example: One bank wrote clear AI policies, integrated training, and set risk thresholds—any tool below a certain security score was automatically unsanctioned. This managed AI without blocking it entirely.
Your Action Plan:
Why It Matters: Vendor-related incidents are increasing. Simple security questionnaires aren't enough—examiners expect documented, tiered risk assessments.
Vendor Risk Tiers:
Tier 1 (Critical): Payment processors, core banking systems, cloud infrastructure
Tier 2 (High): Fintech partnerships, credit reporting agencies, backup/disaster recovery
Tier 3 (Standard): Non-critical vendors
Your Action Plan:
Why It Matters: Tiered management focuses effort on high-impact vendors and demonstrates risk-based governance to examiners.
Why It Matters: Boards make budget and strategy decisions. Security reporting must translate technical achievements into business language.
What Boards Actually Want to Understand:
Better Board Reporting Examples:
❌ Technical language: "We implemented advanced threat detection with ML models for anomaly detection across 47 network segments."
✅ Business language: "Our new threat detection system reduced phishing incidents by 60%, protecting both our members and our operations from costly service disruptions."
❌ Technical language: "We achieved 94% CVSS remediation compliance with mean time to remediation of 21 days."
✅ Business language: "We've reduced critical vulnerabilities by 80% over the past year, lowering the risk of operational disruption and member data exposure."
Your Action Plan:
Why It Matters: Examiners respect institutions that measure themselves against industry standards (NIST, CIS, etc.) and demonstrate quarter-over-quarter improvement.
Maturity Tracking Approach:
Why It Matters: This demonstrates institutional commitment to continuous improvement and gives examiners a clear picture of your security posture relative to standards.
Why It Matters: Budget season is here. Institutions winning board approval focus on optimization and operational efficiency, not just new tools.
Strategic Priorities for 2026:
Optimization:
Innovation:
Awareness:
Your Action Plan:
Q1 (Next 30 Days):
Q1-Q2 (60-90 Days):
Ongoing (Quarterly):
✓ Evidence of continuous compliance system (ticketing, task automation, regular collection)
✓ Functional test results (failover tests, ransomware recovery drills, incident response exercises)
✓ Vendor risk assessments categorized by tier with documented reviews
✓ Vendor contracts with specific incident notification requirements and breach obligations
✓ AI governance policy, risk assessment, and approved AI use cases
✓ AI-specific incident response playbooks
✓ Board meeting minutes documenting security briefings in business language
✓ Maturity tracking dashboard showing quarter-over-quarter improvement
✓ Evidence of third-party and fourth-party vendor mapping
Financial institutions that succeed in 2026 exams—and beyond—treat cybersecurity and compliance as core business functions, not annual chores.
Key Principles:
By implementing these strategies now, your institution will not only pass 2026 exams confidently—you'll strengthen your actual security posture and better protect your members and operations.
Check out the Cyber Risk Management Model that examiners reference below